Regulatory Alerts2025-11-14 | EPD Circular Letter No. 10Framework for Managing Risks of Trade Based Money Laundering and Terrorist Financing
This framework mandates that Authorized Dealers (ADs) implement comprehensive risk management policies to detect and mitigate Trade Based Money Laundering (TBML) and Terrorist Financing (TF) risks through robust governance, independent oversight, and technology-driven transaction monitoring. ADs are required to conduct rigorous customer due diligence, specifically focusing on trade-related risk profiles, financial statement analysis, and price verification against fair market benchmarks. The document provides detailed red flag indicators and specific case study examples to assist staff in identifying high-risk trade activities that necessitate enhanced due diligence and suspicious transaction reporting.
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